MSI Privacy Policy

(A) This Policy

Summary – This Policy

This Policy explains how we Process Personal Data. This Policy may be amended or updated from time to time, so please check it regularly for updates.

This Policy is issued by each of the Controller entities listed in Section (R) below (together, “ MSI ”, “ we ”, “ us ” and “ our ”) and is addressed to individuals outside our organisation with whom we interact, including customers, visitors to our Sites, users of our Apps, other users of our products or services, and visitors to our premises (together, “ you ”). Defined terms used in this Policy are explained in Section (S) below.

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.

(B) Collection of Personal Data

Summary – Collection of Personal Data

We collect or obtain Personal Data: when those data are provided to us (e.g., where you contact us); in the course of our relationship with you (e.g., if you make a purchase); when you make Personal Data public (e.g., if you make a public post about us on social media); when you download, install, or use any of our Apps; when you visit our Sites; when you register to use any of our Sites, Apps, Products, or services; or when you interact with any third party content or advertising on a Site or in an App. We may also receive Personal Data about you from third parties (e.g., law enforcement authorities).

Collection of Personal Data: We collect or obtain Personal Data about you from the following sources:

Data provided to us: We obtain Personal Data when those data are provided to us (e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card, or when you submit a job application).

Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., we provide a service to you, or to your employer).

Data you make public: We collect or obtain Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).

App data: We collect or obtain Personal Data when you download or use any of our Apps.

Site data: We collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.

Registration details: We collect or obtain Personal Data when you use, or register to use, any of our Sites, Apps, Products, or services.

Content and advertising information: If you interact with any third party content or advertising on a Site or in an App (including third party plugins and cookies) we receive Personal Data from the relevant third party provider of that content or advertising.

Third party information: We collect or obtain Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).

(C) Creation of Personal Data

Summary – Creation of Personal Data

We create Personal Data about you (e.g., records of your interactions with us).

We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us.

Employer details: where you interact with us in your capacity as an employee of a third party, the name, address, telephone number and email address of your employer, to the extent relevant.

Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages or App screens displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.

Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.

(E) Sensitive Personal Data

Summary – Sensitive Personal Data

We do not seek to collect or otherwise Process Sensitive Personal Data. Where we need to Process Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.

We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);

Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud);

Establishment, exercise or defence of legal rights: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal rights; or

Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the Processing of those Sensitive Personal Data.

The purposes for which we Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

Processing activity

Legal basis for Processing

Provision of Sites, Apps, Products, and services: providing our Sites, Apps, Products, or services; providing promotional items upon request; and communicating with you in relation to those Sites, Apps, Products, or services.

The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or

We have a legitimate interest in carrying out the Processing for the purpose of providing our (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary
– it is not used for Processing that is necessary or obligatory in any way).

The Processing is
necessary in connection with any contract
that you have entered into with us, or to take steps prior to entering into a contract with us; or

We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, our Apps, our products, or our services to you (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary
– it is not used for Processing that is necessary or obligatory in any way).

Communications and marketing: communicating with you via any means (including via email, telephone, text message, social media, post or in person) to provide news items and other information in which you may be interested, subject always to obtaining your prior opt-in consent to the extent required under applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required.

The Processing is
necessary in connection with any contract
that you have entered into with us, or to take steps prior to entering into a contract with us; or

We have a legitimate interest in carrying out the Processing for the purpose of contacting you, subject always to compliance with applicable law (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary
– it is not used for Processing that is necessary or obligatory in any way).

Management of IT systems: management and operation of our communications, IT and security systems; and audits (including security audits) and monitoring of such systems.

The Processing is necessary for compliance with a legal obligation; or

We have a legitimate interest in carrying out the Processing for the purpose of managing and maintaining our communications and IT systems (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

Health and safety: health and safety assessments and record keeping; providing a safe and secure environment at our premises; and compliance with related legal obligations.

The Processing is necessary for compliance with a legal obligation; or

We have a legitimate interest in carrying out the Processing for the purpose of ensuring a safe environment at our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

The Processing is necessary to protect the vital interests of any individual.

We have a legitimate interest in carrying out the Processing for the purpose of managing and operating the financial affairs of our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary
– it is not used for Processing that is necessary or obligatory in any way).

Surveys: engaging with you for the purposes of obtaining your views on our Sites, our Apps, our products, or our services.

We have a legitimate interest in carrying out the Processing for the purpose of conducting surveys, satisfaction reports and market research (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary
– it is not used for Processing that is necessary or obligatory in any way).

The Processing is necessary for compliance with a legal obligation; or

We have a legitimate interest in carrying out the Processing for the purpose of ensuring the physical and electronic security of our business and our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.

The Processing is necessary for compliance with a legal obligation; or

We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, breaches of our policies and applicable laws (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

The Processing is necessary for compliance with a legal obligation; or

We have a legitimate interest in carrying out the Processing for the purpose of establishing, exercising or defending our legal rights (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

We have a legitimate interest in carrying out the Processing for the purpose of improving our Sites, our Apps, our products, or our services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary
– it is not used for Processing that is necessary or obligatory in any way).

Fraud prevention: Detecting, preventing and investigating fraud.

The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); or

We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, fraud (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); or

We have a legitimate interest in carrying out the Processing for the purpose of recruitment activities and handling job applications (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary
– it is not used for Processing that is necessary or obligatory in any way).

(G) Disclosure of Personal Data to third parties

Summary – Disclosure of Personal Data to third parties

We disclose Personal Data to: legal and regulatory authorities; our external advisors; our Processors; any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business; and any third party providers of advertising, plugins or content used on our Sites or our Apps.

We disclose Personal Data to other entities within the MSI group, for legitimate business purposes and the operation of our Sites, Apps, Products, or services to you), in accordance with applicable law. In addition, we disclose Personal Data to:

you and, where appropriate, your appointed representatives;

legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;

accountants, auditors, lawyers and other outside professional advisors to MSI, subject to binding contractual obligations of confidentiality;

third party Processors (such as payment services providers; shipping companies; etc.), located anywhere in the world, subject to the requirements noted below in this Section (G);

any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights;

any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;

any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and

any relevant third party provider, where our Sites and our Apps use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

(H) Profiling

Summary – Profiling

Personal Data are subject to automated decision-making and Profiling.

We Process Personal Data for the purposes of automated decision-making and Profiling, which is carried out for the following purposes:

Profiling activity

Logic of the Profiling activity

Consequences for you

Credit scoring

Where we engage a third party (e.g., a credit reference agency) to provide us with information about your credit score and/or credit history. This information is analysed to determine the most appropriate terms on which to offer you credit, where applicable.

This Profiling activity may affect whether you are able to obtain credit, and the interest rates applicable to any such credit.

Customised discounts

Where we analyse your purchasing activity and your interests. This information is analysed to determine the most appropriate promotions and discounts to offer you.

This Profiling activity may mean that you receive discounts that are not available to others, and that others receive discounts that are not available to you.